- 4 - for failure to pay estimated tax pursuant to section 6654 for 1990 and 1991. (15) Whether respondent correctly applied the Consumer Price Index (CPI) to petitioners' 1989 joint return figures to determine petitioners' 1990 and 1991 tax liability, and to establish asserted increased liabilities. Respondent concedes that petitioners are entitled to a filing status of "married, filing joint return." FINDINGS OF FACT Some of the facts have been stipulated. The stipulation of facts and the attached exhibits are incorporated herein by this reference. Petitioners were residents of Stockton, California, when they filed their petitions. Doyle is primarily a real estate broker. In 1990 and 1991, and in prior years, he owned and operated a real estate brokerage business under the name of Delta Valley Realty (Delta Valley). During 1990 and 1991, Yvonne worked at Delta Valley as a real estate agent. In 1990, Yvonne received non-employee compensation income of $111,855 from Delta Valley as reported on a Form 1099. In the same year, she had Form 1099 non-employee compensation income of $1,998 from Phoenix International Marketing Corporation of Sparks, Nevada. Neither petitioner filed a timely Federal income tax return for 1990 or 1991. However, copies of signed joint returns for 1990 and 1991 were stipulated. Respondent's opening brief states that thesePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011